CAFE Standards

 

In 1974, the Corporate Average Fuel Economy (CAFE) program was introduced. Beginning in the 1975 model year, automobile makers in the United States would be required to meet average requirements for fuel efficiency on many of their vehicles. At the time of its introduction, and in fact ever since, these standards, and other related policy items, have been a point of contention between automakers, environmentalists, and policy makers. This paper will attempt to shed some light on the strengths and weaknesses of CAFE regulation. We will begin with an introduction to the history of the CAFE program. Following this will be a discussion of the goals of CAFE, followed by an evaluation of how well those goals have been achieved. Next, we will look at the economic efficiency of the program (based on the principles of economic efficiency defined by Tietenberg and others, who take into account externalities)[1], by discussing some of the costs and benefits of the program. Finally, we will draw what conclusions are possible from the data, and discuss alternative interpretations based on other readings of the data.

 

1. What is CAFE?

 

            According to the Executive Director of the National Highway Traffic Safety Administration in 2001, CAFE was “[e]nacted in 1975 in response to the energy crisis caused by the 1973-1974 oil embargo” and “requires motor vehicle manufacturers to ensure that their new-vehicle fleets meet a specified average level of fuel economy in each model year”[2]. This involves each automobile company testing “one vehicle in each base level (combination of inertia weight classes (250 to 500 pound increments), transmission class (type of transmission such as Manual 4-speed), and basic engine (engine size, number of cylinders, and type of fuel system; such as: 5.0- liter, 8 cylinder, multi-point fuel injected engine).” Each unit is tested on a set course (two courses, actually – one for ‘city’ driving and one for ‘highway’ driving) and the results are then reported to the EPA, which will re-check approximately 30% of the tests for accuracy. These results are then grouped into either passenger cars or one of the truck categories (2WD, 4WD, or combined, depending on manufacturer preference and the year under review), weighted by sales, and the harmonic average of these numbers is taken to determine compliance[3].

            The average fuel economy of each corporation is compared to the requirements for the given year (see table 1 – next page) and if a company is found to be non-compliant, they are fined five dollars for each tenth of one mile the vehicle is short of meeting the standard, multiplied by the number of vehicles produced. These fines are collected by the National Highway Transport Safety Association, which can also grant exceptions and set alternative standards. Credits can also be earned and applied to past or future infractions (up to three years in either direction)[4].





Fuel Economy Standards for Passenger Cars and Light Trucks

Model Years 1978 through 2003 (in MPG)

Model Year

Passenger Cars

Light Trucks (1)

 

 

Two-wheel Drive

4WD

Combined (2), (3)

1978

18.0 (4)

...

...

  ...

1979

19.0 (4)

17.2

15.8

  ...

1980

20.0 (4)

16.0

14.0

     ...(5)

1981

22.0

  16.7(6)

15.0

     ... (5)

1982

24.0

18.0

16.0

17.5

1983

26.0

19.5

17.5

19.0

1984

27.0

20.3

18.5

20.0

1985

27.5(4)

19.7(7)

  18.9(7)

  19.5(7)

1986

26.0(8)

20.5

19.5

20.0

1987

26.0(9)

21.0

19.5

20.5

1988

26.0(9)

21.0

19.5

20.5

1989

26.5(10)

21.5

19.0

20.5

1990

27.5(4)

20.5

19.0

20.0

1991

27.5(4)

20.7

19.1

20.2

1992

27.5(4)

...

...

 20.2

1993

27.5(4)

...

...

20.4

1994

27.5(4)

...

...

20.5

1995

27.5(4)

...

...

20.6

1996

27.5(4)

...

...

20.7

1997

27.5(4)

...

...

20.7

1998

27.5(4)

...

...

20.7

1999

27.5(4)

...

...

20.7

2000

27.5(4)

...

...

20.7

2001

27.5(4)

...

...

20.7

2002

27.5(4)

...

...

20.7

2003

27.5(4)

...

...

20.7

1 - Standards for MY 1979 light trucks were established for vehicles with a gross vehicle weight rating (GVWR) of 6,000 pounds or less.  Standards for MY 1980 and beyond are for light trucks with a GVWR of 8,500 pounds or less.

2 - For MY 1979, light truck manufacturers could comply separately with standards for four-wheel drive, general utility vehicles and all other light trucks, or combine their trucks into a single fleet and comply with the standard of 17.2 mpg.

3 - For MYs 1982-1991, manufacturers could comply with the two-wheel and four-wheel drive standards or could combine all light trucks and comply with the combined standard.

4 - Established by Congress in Title V of the Motor Vehicle Information and Cost Savings Act.

5 - A manufacturer whose light truck fleet was powered exclusively by basic engines which were not also used in passenger cars could meet standards of 14 mpg and 14.5 mpg in MYs 1980 and 1981, respectively.

6 - Revised in June 1979 from 18.0 mpg.

7 – Revised in October 1984 from 21.6 mpg for two-wheel drive, 19.0 mpg for four-wheel drive, and 21.0 mpg for combined.

8 – Revised in October 1985 from 27.5 mpg.

9 – Revised in October 1986 from 27.5 mpg.

10 - Revised in September 1988 from 27.5 mpg.

 

Table from: U.S. Department of Transportation,

“Automotive Fuel Economy Program Annual Update Calendar Year 2001”


2. Why Fuel Economy?

            On the government web site fueleconomy.gov, operated by the United States Environmental Protection Agency and the United States Department of Energy, there is a link which asks “Why is Fuel Economy Important?” According to the page pointed to by this link, under the heading “Why should YOU [sic] care about fuel economy?” there are four important items influenced by fuel economy. In order, they are “Protect the Environment,” “Conserve Resources for Future Generations,” “Reduce Oil Imports,” and “Save Money.”[5] All of these items would seem to be fairly important, and as such we will examine each one in the hopes of further explicating what CAFE is trying to accomplish.

            The first item, protecting the environment, is fairly clear cut on its surface – driving cars pollutes the environment. Generally there are four chemicals or emissions discussed when describing auto pollution. These are Carbon Monoxide (CO), Hydrocarbons, Nitrogen Oxides (NOx) and Particulate Matter.[6]  Carbon monoxide is produced during combustion and has an immediate effect on people exposed to it. Although it can affect healthy people in closed spaces, it is more likely to affect those with heart or respiratory diseases. According to the EPA, carbon monoxide is atypical of air pollutants in that its concentrations peak during during cooler seasons, rather than warmer.[7] Hydrocarbons and NOx work together to form ozone, which at ground level causes problems with breathing and even lung damage in humans, and can effect vegetation as well. Many hydrocarbons are also considered “toxic”, meaning the EPA has reason to believe they can cause cancer or other serious health problems.[8] Nitrogen Oxides, which are capable of traveling long distances, can also assist in the formation of particulate matter. Particulate matter, especially very fine particulate matter, can penetrate the lungs, and is associated with a wide range of health problems, including in some cases cancer. In addition to its effects on human health, particulate matter is a cause of haze, and is also capable of traveling long distances. Most mobile-source particulate matter is attributed to diesel engines.[9] CAFE addresses these issues because, presumably, more fuel efficient cars pollute less.

            The second and third items on the list, ‘conserving resources for the future’ and ‘reducing oil imports’, are also quite clear – if fuel economy increases, ceteris paribus, fuel consumption will decrease. If fuel consumption decreases, it would seem logical that the U.S. would need to import less oil, which could bring about any number of positive effects.

            The final item in our list of reasons for increased fuel economy is saving money. It would seem difficult to dispute this. If the average American drives 15,000 miles (this is the number the EPA uses to determine annual fuel costs) and an average gallon of gasoline costs $1.25 (a combination of statistics and current regional prices)[10] then at the CAFE requirement of 20.7 mpg (for trucks) one would spend $905.80 per year. On the other hand, using the passenger car requirement of 27.5 mpg, one would spend $681.82 per year, a savings of $224 per year. Using very rough estimates, then, a car which gets 27.5 mpg, kept for seven years (or 105,000 miles), would have present net benefits equal to $1361 (using a 5% discount rate) over a truck which gets 20.7 mpg. This could be a sizeable portion of the total cost of purchasing the vehicle.

            Were one to solve the problems listed above, it would certainly seem to have a dramatically positive effect on the environment and the economy. So the question now becomes, does increased fuel efficiency (in the form of CAFE regulations) deal with these problems?

 

3. Does CAFE accomplish its own goals?

 

            In August of 2001, under the title “Another cup of CAFE, please.” the editors of Scientific American magazine stated “Improving fuel economy is a worthy national goal: it would reduce America's dependence on imported oil and cut the carbon emissions that contribute to global warming.”[11] Considering the revisions done shortly after that to the strategic position of the United States, it seems important to carefully evaluate this statement.

            One very quick and easy method for evaluating the question of oil use is to look at miles driven per year as compared to required fuel mileage in cars and trucks. Although this does not give us replacement rates (i.e. how many old cars are still on the road), it does give us a benchmark. Since we know mpg rates will (in most cases) be over-inflated, if oil usage remains steady, or increases, we will have fairly strong evidence that CAFE is not succeeding in that part of its goals. For the first decade, Mark Dreyfus’ work indicates that oil usage fell slightly:

Since 1978, the first year in which manufacturers were required to meet CAFE standards, fleet fuel economy has grown 40 percent from approximately 20 mpg to over 28 mpg in 1991 (USDOT various years). Although the fuel economy achieved by the new car fleet improved substantially, total gasoline consumption fell only 2.5 percent by 1987 as the total number of miles traveled in the U.S. rose from 1.1 trillion to 1.4 trillion by 1988 (USDOT 1990).[12]

 

However, as one can see from the following tables, observed fuel efficiency has not changed

 

dramatically since 1991.


 

CAFE PERFORMANCE CARS                     CAFE PERFORMANCE LIGHT TRUCKS

 

In order to get vehicle mile data through the year 2000, we will use the U.S. Department of Transportations numbers, which differ slightly from the numbers discussed in Dreyfus’ work but which allow us to get a more complete view of vehicle miles driven from 1960 to 2000.[13]

Year

1960

1970

1975

1980

1990

1995

2000

Vehicle Miles (trillions)

0.58

1.04

1.23

1.4

1.98

2.23

2.53

 

Using this data, and assuming the mix of domestic and foreign oil has not changed too dramatically, fuel economy standards would have had to improve by over 25% between 1990 and 2000 to account for the increased mileage driven. Note this would not decrease oil usage, merely hold it steady.

image 1: cafe performance passenger cars from 1977 - 2001cafe performance light trucks from 1978 - 2001In contrast to this, we see fuel economy performance has held steady, or in the case of imports actually decreased since 1990. In fact the fuel economy of imports has declined more or less steadily since the early 1980’s, [14] though this is possibly as much due to international trade issues as to CAFE.

            Given the data, it seems safe to conclude that oil usage has not decreased in the last decade. In addition, combined with the vehicle miles driven per year this data indicates that, if people are actually getting vehicles with higher fuel efficiency, they are choosing to drive more rather than save money. Although there are probably more vehicles on the road than in previous years, new car production has not increased dramatically[15]. As such, I do not think the increase in vehicle miles can be completely attributed to an increased vehicle population. In fact, estimates indicate that “for every 10 percent increase in fuel efficiency, people increase their driving by two percent.”[16]

            Given this increase in driving, can the CAFE regulations reach their other goal, that of pollution reduction? For evaluating pollution reduction, CAFE by itself is something of a red herring, since other acts of legislation, such as the clean air act, have had much more important effects on emissions standards. However, there are two important points about CAFE which address the question of its effectiveness in reducing pollution. The first is that pollution is always measured in units per vehicle mile. Thus, if everything else had remained constant, the increased driving brought about by CAFE would have resulted in greater, not lesser, pollution. The second piece of data relates to the fact that other pieces of legislation have made each successive generation of automobiles pollute less per mile traveled. It is argued that by raising pollution standards and the fuel economy standards the costs of new cars will rise, and more consumers will continue to drive their older, more environmentally unfriendly cars.[17]

            This second point, regarding the cost of new cars, specifically as it relates to fuel efficiency, is often raised when discussing CAFE standards. This is a contentious point. Although many sources cite the increased cost of cars as a serious problem with CAFE, many other sources indicate that fuel economy standards could be raised by a significant percentage without increasing the cost of the vehicle. The graphs on page 7 give an indication of this contention, since vehicles now over 20 years old were able to achieve fuel efficiencies of over 30 miles per gallon. For example, in 1971 a Ford Torino weighed 3302 pounds, and got 19 miles per gallon.[18]  The 2003 Ford Taurus weighs 3336 pounds and gets 20 MPG in the city, 28 Highway.[19] Considering the advances in technology of the past 30 years, I am inclined to believe higher fuel economy could be achieved at much lower cost than the numbers provided by the automotive companies. Unfortunately, theirs are the only numbers available to work with.

            In conclusion, upon reviewing the data for whether or not CAFE has achieved its stated goals, I believe the evidence points to an almost complete failure of the program to alleviate the perceived problems it was designed to combat.

 

4. An Economic Evaluation of Fuel Economy Standards

 

As with most things economic, there are two sides to the question of efficiency – what are the costs, and what are the benefits? The question of an efficient level of fuel economy is no different. Too rigid a standard would result in placing an excessive cost burden on manufacturers and, presumably, automobile buyers. Too lax a standard would result in excessive gasoline usage, placing a burden upon drivers as well as forcing the state to acquire additional oil resources, resulting in higher research and development costs and, assuming oil is on the list of resources with security premiums attached, adding additional security costs. Although it is outside the scope of this paper to attempt to model whether CAFE is efficient, it is worthwhile to consider which elements should be included in such a model, and state the assumptions which would accompany their inclusion.

We will begin by evaluating the costs of the government requiring a certain fuel efficiency. These costs are first and foremost the administrative costs of the program. Second is the cost to automotive companies. These costs will directly affect the third component, the costs to consumers. And finally, we will look at external costs – those effects which are not reflected in the monetary evaluation.

To begin with, there are the administrative costs to the government of any regulative program. The official numbers are that the National Highway Traffic Safety Association spends approximately $60,000 per year administering CAFE (along with some other related data gathering tasks).[20] Although they have requested this number be increased to $1,000,000 for FY 2003, it appears going back to 1999 they have had at most $60,000 in funding (excluding 1999 when no funds were appropriated!) The numbers in the budget are extremely small, and as such I make the assumption funds are also listed under other programs. If the numbers in the budget are correct, administrative costs for CAFE are not a major component of the programs total economic effect.

            The costs to automobile companies, on the other hand, are generally considered to be a major component of the total costs of CAFE (at least according to the companies themselves). One study found that “increasing the CAFE standards by 3 mpg would reduce annual profits at General Motors by $433 million, at Ford by $455 million, and at Chrysler by $236 million. Total losses to U.S. automakers would amount to $1.124 billion. In contrast, foreign manufacturers would see an increase in profits of $260 million.”[21] Where do these costs come from? In the early years of CAFE, automakers reduced the weight of cars and used smaller engines to obtain additional fuel efficiency. However, by 1984 it has been estimated that technology improvements outstripped weight cutting as the primary source of fuel economy improvements.[22] So research and development contribute to the cost for automakers. Another often cited cost to automakers is consumers’ tastes and preferences. If consumers want big cars with powerful engines (i.e. if consumers want less fuel efficient cars) then CAFE will not allow U.S. automakers to meet these demands. Foreign competitors, who are able meet those needs, will therefore take market share away from domestic producers.[23] In addition to all these, there are the fines levied for not meeting CAFE standards, which amounted to 33.4 million dollars in 2001.

CAFE FINES COLLECTED DURING CALENDAR YEAR 2001

Model Year

Manufacturer

Amount Fined

Date Paid

1999

Volkswagen of America, Inc.

$224,840

02/01

Fiat Motors of North America

1,066,395

04/01

Lotus Cars USA, Inc.

51,909

12/01

2000

BMW of North America1

26,408,646

06/01

BMW of North America2

971,696

06/01

Porsche Cars North America, Inc.

3,720,816

06/01

Volkswagen of America, Inc.

276,309

08/01

Fiat Motors of North America

686,521

12/01

 

1BMW passenger car fleet

2BMW light truck fleet

 

Table from NHTSA Automotive Fuel Economy Program Annual Update Calendar Year 2001


            The costs of CAFE to consumers is directly related to the costs of automakers, since most costs will be passed on in the price of the car. This can have a profound effect economically, as Andrew Kleit noted in Regulation magazine:

With respect to consumers, losses are measured in terms of the economic concept of "consumer surplus." For example, assume a consumer values a car for $20,000, and is able to purchase it for $18,000. That consumer would gain $2,000 in consumer surplus. If CAFE standards make that car unavailable and the consumer chooses not to purchase a car, the new standards would have caused a loss of $2,000 in consumer surplus for that consumer. If the fuel efficiency standards were to be increased 3 mpg, I estimate that U.S. consumer surplus would decline $1.841 billion.[24]

 

A related effect, one more difficult to assign a price to, is the reduction in choices the consumer may have if CAFE limits change the mix of domestically produced vehicles. If domestic producers are “’mix-shifting’ - selling fewer large cars and more small cars by raising prices on the former and lowering them on the latter”[25] the consumer will have fewer cars to choose from at certain price points.

            In addition to the costs the government, producers, and consumers will have to pay in direct terms, there are also several external costs to be considered. Many of these are related to the previously mentioned fact that higher fuel economy results in more vehicle miles. Higher vehicle miles results in more pollution, additional congestion[26], and additional roads built to relieve congestion.[27] Additional roads have a significant social and environmental impact, including impact on soils, water supplies, flora and fauna, and land use.[28]

A possible external effect of CAFE which has been quite controversial is the concept of safety. As mentioned earlier, one of the routes auto makers took to improve safety was reducing the weight of the automobile. This led many to the conclusion that fatalities would rise. An example of this idea, used as evidence before the senate, stated that “the 27.5 mpg CAFE standard for passenger cars was responsible for a 500-lb. drop in the average weight of a new car, and that this translated into a 14-27 percent increase in occupant fatalities--2,200 to 3,900 additional traffic deaths per year.”[29] Using virtually any reasonable valuation on life, this would be a tremendous negative externality. However, evidence is mixed on the actual effect of reduced vehicle weights on safety. Because of the complexity required of any model which attempts to separate driver related variables from vehicle related variables, studies are thoroughly mixed on whether CAFE has actually caused additional deaths.[30] One study for example found that drivers of smaller cars were more cautious, which resulted in fewer accidents.[31] Other studies involving vehicles of differing masses colliding with fixed objects (for example, telephone poles or trees) indicated that lighter vehicles had higher fatality rates. These studies as a whole show that the definition of safety is quite malleable, and depending on how it is defined lighter vehicles can be viewed as ‘more’ or ‘less’ safe. The debate over safety as it relates to changes in vehicle weight will probably last far longer than the debate over CAFE.

An externality which is much less in dispute with regard to safety, however, is the relationship of accidents to vehicle miles. It is generally agreed that there is a relationship between the number of miles driven and the number of accidents which will occur. Generally, insurance is paid for based on the length of time and the assumed risk of the driver. As such there is no marginal cost to driving additional miles, despite the fact that there is a societal cost to additional miles being driven.[32]

 

 

Motor Vehicle Crash Death Rates, 1950-1998.

Source: National Safety Council, Injury Facts, 1999 Edition[33]

 

            Other items which must be considered on the cost side include noise pollution, increased road maintenance costs[34], disposal costs[35] (if the assumption is made that cars are wearing out more quickly due to the increased miles driven) and - a subject popular near universities - parking.[36]

            Overall, the external costs appear to be more numerous and also more difficult to value

than the costs to consumers, producers, or the government. A complete econometric evaluation of costs is going to be seriously contingent on the safety issue, since estimates range from zero (assuming there is no safety issue) to $9,750,000,000 (using the 3900 death high end Crandall and Graham computed and multiplying by 2.5 million dollars per death).[37]

The benefits of legislated fuel economy, in contrast to the costs, are easier to enumerate, and for the most part to assign a value to. For example, with higher fuel economy vehicles, consumers spend less on gasoline per mile traveled. According to the NHTSA, lifetime savings for vehicles manufactured under CAFE regulations (1977 for cars and 1978 for trucks) were as follows:

 

Reduced Fuel
Consumption

Dollar
Value

Total (All Vehicles)

45.6 billion gallons

(1.1 billion barrels)

$53.8 billion

Per Vehicle

974 gallons

$1,146

From: NHTSA and Parsons, National on road survey

 

We can thus put a direct number on the savings to consumers for driving any particular number of miles. The question as to whether they would drive those miles were their cars less fuel efficient is one which would be very difficult to answer, but regardless of whether the benefits are in the form of extra money or in the form of marginal social side benefits accruing from the extra miles driven, the benefits do occur. Putting a value on being able to drive extra miles might be found by monitoring miles driven versus current fuel prices for different regions.

            A more difficult number to quantify is the ‘feel-good factor’ of driving a more fuel efficient vehicle. Since it is widely accepted that more fuel efficient vehicles are good for the environment, many would assign a certain amount of value to the appearance of being more ‘earth-friendly’ given by driving a more fuel efficient vehicle. Some would even argue driving a less fuel efficient vehicle imperils one’s soul. According to the ‘What Would Jesus Drive’ campaign, “Making transportation choices that threaten millions of human beings violates Jesus' basic commandments: ‘Love your neighbor as yourself’ (Mk. 12:30-31); and ‘Do to others as you would have them do to you’ (Lk. 6:31).”[38]

 

5. Conclusions

CAFE was enacted with the goal of reducing American dependence on foreign oil, controlling pollution, and meeting the needs of consumers at the time for more fuel efficient vehicles. Unfortunately, what was enacted served none of those purposes efficiently. In section three we evaluated the success of CAFE in addressing the issues for which it was designed, and it was shown that in many instances the benefits of increased fuel economy were either less than expected or completely nonexistent. The growth of vehicle miles in response to higher fuel economy would seem to have increased, rather than decreased, pollution. The effect on oil consumption is more complex, in that although the effect of increased fuel economy on number of miles driven is clear, whether or not this was in response exclusively to increased fuel economy is not definite. As Tietenberg points out, “Low transport cost encourages dispersed settlement patterns…. Once settlement patterns are dispersed it is difficult to justify high volume transportation alternatives….”[39] I do not believe any model will be able to tell us whether suburbanization was driven to its present level because of increased fuel economy. My personal belief is that consumption would have increased regardless, in which case CAFE has reduced oil consumption, and should be moved from the ‘costs’ column to the ‘benefits’ column. Were one to make the assumption CAFE had actually driven urban sprawl, however, then it would be responsible for increased, rather than decreased, consumption. The remaining factor, consumer demands for more fuel efficient vehicles, could most likely have been dealt with more effectively by letting market forces do their work. In addition, any increase in vehicle miles CAFE was responsible for exasperated already existent externalities. Specificity says that one should deal with problems at their source. In this case, legislation was enacted which attempted to deal with multiple problems and in doing so dealt with none of them. Although we did not develop exact numbers here for the costs and benefits of CAFE, it is quite clear that the costs were many and the benefits fewer than expected. In addition, by choosing a politically powerful industry to regulate, congress ensured that any legislation which could be enacted would be too little, too late, and would come at enormous cost to the taxpayers footing the bill for endless hearings, committee meetings, industry consultations, and so forth. Overall CAFE has not encouraged an efficient level of oil consumption, and does not appear destined to in the future.
Bibliography

 

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http://www.nap.edu/html/cafe/

 

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TAXES AND CAFE STANDARDS: DISCOUNTING AND VALUATIONS OF VEHICLE SAFETY CHANGES” Duke University, August 1993. http://yosemite.epa.gov/

 

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http://www.whatwouldjesusdrive.org/

 

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http://www.house.gov/commerce/telecom/ hearings/052297/kazman.pdf

 

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http://www.nhtsa.dot.gov/nhtsa/whatis/bb/

 

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http://www.nhtsa.dot.gov/cars/rules/regrev/evaluate/806971.html

 

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http://www.epa.gov/OMS/cert/dearmfr/fepfs.pdf

 

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[1] Tietenberg, p. 66

[2] Shelton, 1

[3] U.S. Environmental Protection Agency, “Fuel Economy Program Fact Sheet”

[4] U.S. Environmental Protection Agency, “Fuel Economy Program Fact Sheet”

[5] U.S. Environmental Protection Agency and U.S. Department of Energy, http://www.fueleconomy.gov

[6] U.S. Environmental Protection Agency, “Mobile Source Emissions, Past Present and Future”

[7] U.S. Environmental Protection Agency, “Mobile Source Emissions, Past Present and Future”

[10] U.S. Department of Transportation, Bureau of Transportation Statistics, “National Transportation Statistics 2001”

[11] Scientific American, Editors. “Another cup of CAFE, please.”

[12] Dreyfus, pp. 7-8

[13]  U.S. Department of Transportation, Bureau of Transportation Statistics, “National Transportation Statistics 2001” - note that numbers given are a combination of passenger cars and ‘other 2-axle 4 tire vehicles’ which, prior to 1985, may or may not have included privately owned utility vehicles. Between the two numbers I believe I have caught most CAFE vehicles for the time span.

[14] U.S. Department of Transportation, “Automotive Fuel Economy Program Annual Update Calendar Year 2001”

[15]U.S. Bureau of Transportation Statistics, “National Transportation Statistics 2001”

“Retail Sales of New Cars by Sector”

[16] Kleit, “CAFE changes, by the numbers”

[17] Kleit, “CAFE changes, by the numbers”

[18] Crandall et al. Regulating the Automobile p. 125

[19] Yahoo! Autos – http://cars.yahoo.com

[20] National Highway Traffic Safety Administration, “Budget in Brief”

[21] Kleit, “CAFE changes, by the numbers”

[22] Crandall et al. Regulating the Automobile, p. 136

[23] Kleit, “CAFE changes, by the numbers”

[24] Kleit, “CAFE changes, by the numbers”

[25] Kleit, “CAFE changes, by the numbers”

[26] Tietenberg, p.418

[27] Tietenberg, p.417

[28] Tsunokawa, “Roads and the Environment: A Handbook” p. 61

[29]Kazman, citing a well known study by Crandall & Graham called “The Effect of Fuel Economy Standards on Automobile Safety”

[30]Committee On Effectiveness And Impact Of Corporate Average Fuel Economy (Cafe) Standards, “Effectiveness And Impact Of Corporate Average Fuel Economy (Cafe) Standards”

[31]Yun, p.260

[32]Tietenberg, p.417

[33] Committee On Effectiveness And Impact Of Corporate Average Fuel Economy (Cafe) Standards, “Effectiveness And Impact Of Corporate Average Fuel Economy (Cafe) Standards”

[34] Tietenberg, pp.417-418

[35] Grad et al. p. xiv

[36] Tietenberg, pp.417-418

[37] Kazman citing Crandall and Graham provided the number of deaths, valuation per life has been calculated in multiple sources, with 2.5 million being near the high end.

[38] Evangelical Environmental Network and Creation Care Magazine. “What Would Jesus Drive?”

[39] Tietenberg, p.419